Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Commodity-trading receivables written off as bad debts qualify for deduction where they were previously included in income and written off in the books; a possible future recovery does not justify disallowance. Characterising the transactions as speculative or the amount as capital investment does not displace fulfilment of those conditions. The bad-debt disallowance was deleted, subject to taxation of any later recovery in the year received. For windmill-profit deductions, head-office expenses and depreciation on common assets require factual examination of their components, use and allocation to eligible operations. That computation was remanded for fresh adjudication.
Commodity-trading receivables written off as bad debts qualify for deduction where they were previously included in income and written off in the books; a possible future recovery does not justify disallowance. Characterising the transactions as speculative or the amount as capital investment does not displace fulfilment of those conditions. The bad-debt disallowance was deleted, subject to taxation of any later recovery in the year received. For windmill-profit deductions, head-office expenses and depreciation on common assets require factual examination of their components, use and allocation to eligible operations. That computation was remanded for fresh adjudication.
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